STIPULATION AND [PROPOSED] ORDER ENLARGING TIME FOR BRIEFING ON PLAINTIFF'S MOTION TO COMPEL COMPLIANCE WITH SUBPOENA AND MOTION TO TRANSFER; SUPPORTING DECLARATION OF RAYMOND MARSHALL

SAMUEL CONTI, District Judge.

STIPULATION TO EXTEND TIME TO RESPOND TO MOTIONS

Pursuant to Northern District of California Civil Local Rules 6-1(b), 6-2 and 7-12, Plaintiff Moon Mountain Farms, LLC ("Plaintiff") and Non-party Wells Fargo & Co. ("Wells Fargo") (collectively the "Parties"), by and through their respective counsel, hereby stipulate to extend the briefing schedule on Plaintiff's Motion to Compel Compliance with Subpoena and Motion to Transfer (the "Motions") as follows:

WHEREAS, the Parties who sign this Stipulation constitute all of the parties to this proceeding;

WHEREAS, on April 4, 2014, Plaintiff filed its Notice of Motion and Motion to Compel Compliance with Subpoena; Memorandum of Points and Authorities in Support Thereof and Motion to Transfer;

WHEREAS, currently Wells Fargo's Response is due by May 2, 2014, Plaintiffs Reply is due by May 12, 2014, and the Motions are set to be heard on May 30, 2014, at 10:00 AM;

WHEREAS, the Parties met and conferred on April 28 and April 30, 2014, to eliminate or narrow the scope of the issues underlying Plaintiff's Motion to Compel;

WHEREAS, the Parties have reached agreement on the majority of the issues underlying Plaintiff's Motion to Compel;

WHEREAS, the Parties agree a delay in the briefing schedule will permit Plaintiff sufficient time to review Wells Fargo's production of documents, scheduled to be substantially made on May 5, 2014, such that Plaintiff can determine whether any issues remain in dispute;

WHEREAS, the Parties agree that this extension of time will not jeopardize the disposition of Plaintiffs Motions or the dates for the close of discovery, trial date and related deadlines of the underlying action, pending in the United States District Court for the District of Arizona (2:13-cv-00349-SRB);

THE PARTIES DO HEREBY AGREE AND STIPULATE to the following:

1. Non-party Wells Fargo shall have until Friday, May 16, 2014, to file its Response to Plaintiffs Motions;

2. Plaintiff shall have until Friday, May 23, 2014, to file its Reply in support of its Motions; and

3. The Motions shall continue to be heard on Friday, May 30, 2014 June 6, 2014, at 10:00 AM in Courtroom 1 of this Court, or on the nearest date/time before or after that is convenient for the Court.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.